Last November the Interstate Natural Gas Association of America (INGAA) and the Natural Gas Supply Association (NGSA) jointly petitioned the Commission to initiate a rulemaking to improve blanket certificate procedures. The Commission followed up on that joint recommendation expeditiously, issuing its Notice of Proposed Rulemaking (NOPR) in June in RM06-7. We advised you at the time we filed our comments on August 25th that practical considerations required separate filings. We urged you, however, not to construe this as a sign of departure from the pipeline/producer consensus outlined in our original joint petition for rulemaking.

Our organizations have now had an opportunity to review each other’s comments, which are in agreement on major issues urging the Commission to liberalize restrictions on blanket processing under its proposal. We write today to confirm our mutual general support for each other’s positions.